Construction Waste Management Plan

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SITE-SPECIFIC

CONSTRUCTION
WASTE MANAGEMENT PLAN

FOR

GLL PRS HOLDCO LIMITED

RELATING TO A PROPOSED

STRATEGIC HOUSING DEVELOPMENT, ‘KENELM’

AT

DEER PARK
HOWTH
CO. DUBLIN

21st May 2021

Ian Byrne MSc, MIOA, Dip Environmental & Planning Law

Kenelm - Construction Waste Management Plan


TABLE OF CONTENTS PAGE

1.0 INTRODUCTION 2

2.0 DEVELOPMENT DESCRIPTION 4

3.0 DESCRIPTION OF SITE ACTIVITIES & WASTE ARISINGS 5

4.0 PRINCIPALS OF THE WASTE MANAGEMENT PLAN 8

5.0 WASTE MANAGEMENT AND RESPONSIBILITIES 8

6.0 CONSTRUCTION WASTE MANAGEMENT & DISPOSAL 9

7.0 ON-SITE WASTE REDUCTION REUSE RECYCLING AND MANAGEMENT 12

8.0 WASTE RECORD KEEPING 16

9.0 CONSTRUCTION WASTE MANAGEMENT AUDITING 17

10.0 WASTE EXPORT PERMITS / LICENSES 17

APPENDIX I BY-PRODUCT DETERMINATION DECISION TREE


APPENDIX II WASTE EXPORT LOG
APPENDIX III WASTE CLASSIFICATION REPORT AND SUBSOIL ASSESSMENT

Kenelm - Construction Waste Management Plan


1.0 INTRODUCTION

This document presents a site-specific Construction Waste Management Plan (CWMP)


for the control, management and monitoring of waste associated with the construction of
a proposed residential development at Deer Park, Howth, Co. Dublin.

The proposed application area is greenfield and is enclosed along its northern and
eastern boundaries by a demesne wall. To the south is Deer Park golfclub and to the
west residential dwellings.

A review of historical aerial photography identifies that other than partial use as a
racetrack, which use ceased in 1842, the site has been in its present condition i.e.
greenfield.

The CWMP has been prepared to demonstrate how the Construction Phase will comply
with the following relevant legislation and relevant Best Practice Guidelines:

Waste Management Acts 1996

Waste Management (Collection Permit) Regulations 2007 (SI No. 820 of 2007)

Waste Management (Collection Permit) Amendment Regulations 2008 (SI No. 87 of


2008)

EPA “Guidance on Soil and Stone By-Products in the context of Article 27 of the
European Communities (Waste Directive) Regulations – Version 3 June 2019

Department of the Environment, Heritage and Local Government – Best Practice


Guidelines on the Preparation of Waste Management Plans for Construction and
Demolition Projects – July 2006.

Fingal County Council Development Plan 2017 – 2023 – Construction & Demolition
Waste Management Objectives

The Objective of this CWMP is to minimise the quantity of waste generated by


construction activities, to maximise the use of materials in an efficient manner and to
maximise the segregation of construction waste materials on-site to produce
uncontaminated waste streams for off-site recycling.

The CWMP shall be implemented throughout the construction phase of the development
to ensure the following:

Kenelm - Construction Waste Management Plan


➢ That all site activities are effectively managed to minimise the generation of
waste and to maximise the opportunities for on-site reuse and recycling of waste
materials.
➢ To ensure that all waste materials are segregated into different waste fractions
and stored on-site in a managed and dedicated waste storage area.
➢ To ensure that all waste materials generated by site activities are removed from
site by appropriately permitted waste haulage contractors and that all wastes are
disposed of at approved waste licensed / permitted facilities in compliance with
the Waste Management Act 1996 and all associated Waste Management
Regulations.

2.0 DEVELOPMENT DESCRIPTION

The proposed development comprises construction of a residential scheme of 162 no.


residential units comprised of 1, 2 and 3 bed apartments across 3 no. apartment blocks
(A-C).

FIGURE 1 SITE LOCATION

Kenelm - Construction Waste Management Plan


3.0 DESCRIPTION OF SITE ACTIVITIES & WASTE ARISINGS

Demolition
To facilitate access to the development, it is proposed to provide a vehicular and
pedestrian access to the northwest of the site and a separate pedestrian access to the
north east. This will necessitate partial demolition of the northern demesne boundary
wall. This is the only demolition required to facilitate the development.

The project conservation architect describes the wall as comprising coursed random
rubble construction mainly Calp limestone, the upper section which has been rebuilt and
repointed. The masonry construction is generally limestone laid and originally pointed
with a non-hydraulic lime mortar mix. The evidence of later rebuilding can be seen by the
variation in stone and workmanship.

The method statement for the works proposed to the wall is included as an Appendix to
the Construction Environmental Management Plan prepared by Barrett Mahony
Consulting Engineers included under separate cover.

There are no other structures present on site and accordingly this report deals with
waste arising from the construction phase of the proposed development.

Construction Phase

The range of works required for the Construction Phases are summarised in Table 1.
The expected construction and demolition waste that will be generated throughout the
course of the development are described in Tables 2 - 4 below.

Table 1 Sequence of Construction Works

Activity Sequence General Description

Enabling Works Set up hoarding compound, site stripping


Utility trenches Gas, Electricity, drainage
Basement Excavation Removal of soils off site
Construction of Buildings Piling, superstructure formwork
Mechanical & Electrical installation Drainage, Utility ducts, power
Cladding & Building Fit Out Windows, internal works
Services installation and connections ESB, gas, telecoms
Landscaping, Roads and Footpaths Planting and hard surfaces

Kenelm - Construction Waste Management Plan


Table 2 Typical Construction & Demolition Waste Composition

Description of Waste %

Soils & Stones 76.7


Mixed C&D 7.0
Metals 3.0
Concrete Bricks Tiles, Gypsum 12.0
Wood, Glass, Plastic 0.3
Bitumen Waste 1.0
Totals 100
Source EPA Sept 2020

Table 3 Predicted Construction Waste Generation


Predicted
Waste Type tonnage Re-Use Recyclable Disposal
to be
produced
Tonnage % Tonnage % Tonnage %
Mixed C&D 1202 - - 601 50 601 50
Metals 515 - - 515 100 - -
Concrete, 2060 1030 80 - - 1030 20
Blocks,
Gypsum
Wood Glass 52 - - 5.2 10 46.8 90
Plastic
Bitumen 172 172 100 - -
Total 4000 1030 1293.2 1676.8
Soils 45,000 45,000 100

Kenelm - Construction Waste Management Plan


Table 4 Typical Construction Waste Types

Description of Waste Corresponding LoW Code

Concrete, Bricks, Tiles and Ceramics 17 01


Concrete 17 01 01
Bricks 17 01 02
Tiles and Ceramics 17 01 03
Mixture of concrete, bricks tiles & ceramics 17 01 07
Wood, Glass and Plastic 17 02
Wood 17 02 01
Glass 17 02 02
Plastic 17 02 03
Bituminous mixtures, coal tar and products 17 03
Bituminous mixtures containing other than those mentioned in 17 03 02
17 03 01
Bituminous Mixtures including Coal Tar and Tarred 17.03 02
products
Metals (including their alloys) 17 04
Copper, Bronze, Brass 17 04 01
Aluminium 17 04 02
Lead 17 04 03
Zinc 17 04 04
Iron and Steel 17 04 05
Tin 17 04 06
Mixed Metals 17 04 07
Insulation and Construction Materials 17 06 04
Gypsum based construction material 17 08 02
Mixed Construction and Demolition Waste other than those 17 09 04
mentioned in 17 09 01, 17 09 02, 17 09 03
Sewage Screenings 19 08 01
Paper and Cardboard 20 01 01
Wood other than that mentioned in 20 01 37 20.01 38
Soil and Stones 17 05 04
Mixed Municipal Waste 20 03 01
Hydraulic oils 13 01 01*
Fuel oils and diesel 13 07 01*

Kenelm - Construction Waste Management Plan


4.0 PRINCIPALS OF THE CONSTRUCTION WASTE MANAGEMENT PLAN

Waste materials generated by construction activities will be managed according to the


Department of the Environment, Heritage and Local Government’s 2006 Publication -
Best Practice Guidelines on the Preparation of Waste Management Plans for
Construction and Demolition Projects and with regard to Fingal County Council
Development Plan 2017 – 2023 – Construction & Demolition Waste Management
Objectives.

The CDWMP specifically addresses the following points:

➢ Analysis of waste arisings / material surpluses

➢ Waste Management Responsibilities and Training

➢ Specific Waste Management

➢ Objectives for the Project including the potential to re-use existing on-site materials
for further use in the construction phase.

➢ Methods proposed for Prevention, Reuse and Recycling

➢ Waste Handling Procedures

➢ Hazardous Waste Handling Procedures

➢ Waste Storage Procedures

➢ Waste Disposal Procedures

➢ Waste Auditing

➢ Record Keeping

➢ Waste Collection and Facility Permit Management

5.0 WASTE MANAGEMENT & RESPONSIBILITIES

Project Manager - Roles and Responsibilities

The Project Manager will be responsible for the overall implementation of the CDWMP.
The Project Manager will ensure that the reporting and recording requirements are met
and all necessary resources are in place to support the implementation of the plan.

A technically competent and appropriately trained C&D Waste Officer will be appointed
by the Project Manager. The nominated person will be responsible for all aspects waste
management throughout the different stages of the project including waste assessment
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Kenelm - Construction Waste Management Plan


and characterisation, implementation of the CDWMP (and associated target recycling
rates), and effective communication of the objectives with all the operatives associated
with the project (including site staff, external contractors and suppliers). The C&D Waste
Officer shall be responsible for the management of the construction waste compound.

A key objective of the nominated person will be the maintenance of accurate records on
the quantities of waste / surplus materials generation and management. The recording of
summary information will further assist the implementation of the plan.

6.0 CONSTRUCTION WASTE MANAGEMENT & DISPOSAL

➢ It is proposed that from the outset of construction activities, a dedicated and secure
compound containing bins, and/or skips, and storage areas, into which all waste
materials generated by construction site activities, will be established within the active
construction phase of the development site.

➢ Spill kits shall be located within the waste compound with clearly labelled instructions
on how they shall be used to clean up fuel/oil spills.

➢ All vehicle and plant oils and liquid construction materials shall be stored in
impermeable storage units.

➢ All diesel-powered generators shall be inspected on at least a weekly basis by a


delegate of the project manager to ensure it is not leaking diesel or oils.

➢ All empty containers containing residual quantities of oils, greases and hydrocarbon-
based liquids shall be stored in a dedicated bunded receptacle in the waste
compound.

➢ In order to ensure that the construction contractor correctly segregate waste


materials, it is the responsibility of the C&D waste officer to ensure all staff are
informed by means of clear signage and verbal instruction and made responsible for
ensuring site housekeeping and the proper segregation of construction waste
materials.
➢ It will be the responsibility of the C&D waste officer to ensure that a written record of
all quantities and natures of wastes exported off-site are maintained on-site in a
Waste File at the Project office.

➢ It is the responsibility of the C&D waste officer that all contracted waste haulage
drivers hold an appropriate Waste Collection Permit for the transport of waste loads
and that all waste materials are delivered to an appropriately licenced or permitted
waste facility in compliance with the following relevant Regulations:

Waste Management (Collection Permit) Regulations 2007 (SI No. 820 of 2007)
Waste Management (Collection Permit) Amendment Regulations 2008 (SI No. 87 of
2008)

Kenelm - Construction Waste Management Plan


Waste Management (Facility Permit and Registration) Regulations S.I.821 of 2007
and the Waste Facility Permit under the Waste Management (Facility Permit and
Registration) Amendment Regulations S.I.86 of 2008.

➢ Typical Waste materials that are to be generated or anticipated to be generated by


construction works are classified as follows under Section 17 Construction and
Demolition Wastes of the European Waste Catalogue (EWC) as detailed in Table 4.

➢ It is proposed that waste materials will be collected and stored in separate clearly
labelled skips in a predefined waste storage area in the site compound and that these
materials will be collected by a Permitted Waste Contractor holding an appropriate
Waste Collection permit in compliance with Waste Management (Collection Permit)
Regulations 2007 (SI No. 820 of 2007) and Waste Management (Collection Permit)
Amendment Regulations 2008 (SI No. 87 of 2008) and that they will be sent for
disposal or further processing to appropriately Permitted / Licensed Waste Facilities
in compliance with Waste Management (Facility Permit and Registration) Regulations
S.I. No. 821 of 2007 and the Waste Management (Facility Permit and Registration)
Amendment Regulations S.I. No. 86 of 2008.

➢ Prior to the commencement of the Project, the C&D waste officer shall identify a
permitted Waste Contractor who shall be employed to collect and dispose of all inert
and hazardous wastes arising from the project works. In addition, the C&D waste
manager shall identify all waste licensed / permitted facilities that will accept all
expected waste exported off-site and will maintain copies of all relevant Waste
Permits / Licences as required.

➢ All waste soils prior to being exported off-site, shall be classified as inert, non-
hazardous or hazardous in accordance with the EPA’s Waste Classification Guidance
– List of Waste & Determining if Waste is Hazardous or Non-Hazardous document
dated 1st June 2015 to ensure that the waste material is transferred by an
appropriately permitted waste collection permit holder and brought to an appropriately
permitted or licensed waste facility.

Construction Waste Compound Design

A dedicated and secure construction waste storage compound shall be located adjacent
to the site offices. The C&D Waste Manager shall be responsible for the management of
the construction waste compound. The area shall be demarcated by fencing and shall be
of sufficient size to house a minimum of 4 x 20 cubic yard roll on roll off skips for
construction waste materials and 1 x 14 cubic yard covered skip for mixed municipal
wastes generated by site staff.

All subcontractors shall be instructed by the C&D Waste Officer to remove their waste
off-site from their work areas on a daily basis

Signage shall be installed at each skip to clearly identify the nature of waste that may be
placed within it.

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Kenelm - Construction Waste Management Plan


Spill kits and mobile bunds as shown in Figures 3 & 4 will located within the waste
compound.

Figure 2 Typical construction waste segregation compound design

Individual construction waste skips shall accommodate waste wood, metal, plastics,
gypsum products.

Figure 3 Oil Spill Kit Figure 4 Bund for waste oil container storage

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7.0 ON-SITE WASTE REDUCTION REUSE RECYCLING AND MANAGEMENT

Waste will arise on the project mainly from bulk excavation and general construction
activities and site infrastructure construction. The site management team will order
materials and arrange storage in order to minimise the potential for waste on site.

➢ Materials will be ordered on an “as needed” basis to prevent over supply

➢ Materials shall be correctly stored and handled to minimise the generation of


damaged materials

➢ Materials shall be ordered in appropriate sequence to minimise materials stored on


site

➢ All staff and Sub contractors shall be advised through tool box talks on how to
dispose of their waste correctly on-site.

➢ Sub-Contractors will be instructed to remove off-site all waste generated from their
activities on a daily basis.

➢ Concrete blocks, engineering bricks and clay bricks that are surplus will be broken up
and used for hardstanding areas.

➢ Excess wood will be segregated in separate skips and sent for recycling. The site
management will police to make sure that the segregation of the wood skip is kept
exclusively for wood.

➢ Plastic arising from general waste or packaging will be segregated and stored in
separate skips. Again, the site management team will ensure that there is no
contamination of the segregated skips on site.

➢ Top soil that is required for the soft landscaping will be measured and this quantity
will be retained on site. The soil that will have to be removed off site will be removed
to a licenced landfill facility. The C&D Waste Manager. will keep records of the
removal and the certification on file on site.

➢ Any hazardous material discovered during the course of the construction shall be
reported to the C&D Waste Manager. The relevant authorities will be informed and an
agreed method for the removal of the hazardous material.

➢ Construction waste material such as damaged or broken concrete slabs, blocks,


bricks and tiles generated that is deemed by the Project Engineer to be suitable for
reuse on the Project site for ground-fill material will be processed if necessary, by on-
site mobile crushing plant. This initiative shall provide a positive environmental impact
to the construction phase as follows:

➢ Reduction in the requirement for virgin aggregate materials from quarries


➢ Reduction in energy required to extract, process and transport virgin aggregates

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➢ Reduced HGV movements associated with the delivery of imported aggregates to
the site
➢ Reduced noise levels associated with reduced HGV movements
➢ Reduction in the amount of landfill space required to accept C&D waste

Waste Soils & Stones

The Project Engineers, Barret Mahony Consulting Engineers, have estimated that c.
30,000m3 of soils will be excavated to depths between 4.5m – 7m to facilitate the
development and exported from the site.

It is predicted that up to 4,500m3 of soils shall be retained for landscaping works.

Soils at the site have been classified following WAC testing by Ground Investigations
Ireland and the completion of a Waste Classification Assessment. The Waste
Classification Report & Subsoil Assessment is included as Appendix III to this report.

The scope of the work undertaken to facilitate the waste classification exercise included
the following:

• Excavation of twelve (12 No.) trial pits;


• Collection of subsoil samples for chemical analysis;
• Environmental laboratory testing;
• Waste classification; and
• By-product suitability assessment.

In order to assess materials, which may be excavated from site, in terms of waste
classification, a selection of samples collected were analysed for a suite of parameters
which allows for the assessment of the soils in terms of total pollutant content for
classification of materials as hazardous or non-hazardous (RILTA Suite). The suite also
allows for the assessment of the soils in terms of suitability for placement at various
categories of landfill.

The suite was selected due to no evidence of specific contaminants of concern


highlighted in the site history. The laboratory testing was competed by Element Materials
Technology (EMT) in the UK; EMT is a UKAS accredited laboratory. The soil
classification of the Waste Classification Report & Subsoil Assessment is included in
Appendix III.

In total, thirty (30 No.) samples were assessed using the HazWasteOnLineTM Tool. The
location of the trial pits are illustrated in the Figure below.

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Kenelm - Construction Waste Management Plan


Figure 1 Location of Trial Pits

The assessment concluded that on-site soils are classified with LoW Code 17 05 04 may
be classified as non-hazardous and are defined as a Category A Criteria as follows. Soil
and Stone only which are free from anthropogenic materials such as concrete and
timber. Soils must be free from “contamination” e.g. PAH’s, Hydrocarbons and Asbestos.
Category A material can be disposed/recovered at unlined soil recovery facilities.

By-product Suitability (Article 27 Declarations)


Based on the analysis of the samples collected from the on-site excavations the material
sampled is free of contamination. The material sampled was comprised of natural
subsoils which were free of anthropogenic materials. Following an appraisal of the
chemical analysis and the absence of anthropogenic materials the subsoils sampled are
suitable for removal from site as a by-product which will not lead to overall adverse
environmental or human health impacts.

Based on the WAC analysis, it is intended to declare the excavated soils a by-product to
the EPA in accordance with Article 27 of the European Communities (Waste Directive)
Regulations 2011 and the EPA publication “Guidance on Soil and Stone By-Products in
the context of Article 27 of the European Communities (Waste Directive) Regulations –
Version 3 June 2019.

The notification of a potential by-product gives industry an opportunity to demonstrate,


with an appropriate level of rigour, that:
• the material can have a further use and no longer be defined as waste;
• the material can be used as a ‘secondary’ resource in place of, and fulfilling
the same role as a non-waste derived or virgin ‘primary’ resource; and
• the material can be used without causing overall adverse impacts to the
environment or human health.

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The by-product test is made up of four conditions, which represent the requirements of
Article 27. All four of the following ‘conditions’ must be met for an economic operator to
decide that a production residue is a by-product:
1. further use of the material is certain;
2. the material can be used directly without any further processing other than
normal industrial practice;
3. the material is produced as an integral part of a production process; and
4. further use is lawful in that the substance or object fulfils all relevant
product, environmental and health protection requirements for the specific
use and will not lead to overall adverse environmental or human health
impacts.

Based on the type of material to be excavated i.e. virgin soils, the fact that it is being
excavated to facilitate the proposed development and the results of the WAC analysis,
conditions 2-4 above are met.

Regarding Condition 1, at this stage, it is too early to identify a specific site where the
material would be used. This is because, it is necessary first to secure planning
permission to have certainty regarding the availability of the by-product and only then
can a further use be identified. However, having regard to the scale of development
taking place in Dublin, it is reasonably expected that there will be projects seeking to
avail of this by-product. The selected location will be identified in the notification to the
EPA.

Having regard to the WAC analysis, it is deemed unlikely that the excavated soils would
be rejected by the EPA as a by-product. Notwithstanding, should this situation arise the
excess soils would be exported for authorised recovery. All construction waste and soils
will only be exported to authorised waste facilities holding a valid Waste Licence, Waste
Facility Permit or a Certificate of Registration.

Construction waste material will be exported of site by the following permitted waste
collection contractors and shall be transferred to the following facilities:

Waste Soils Carrier Shannon Valley NWCPO-15-11613-01


Receiving Soils Facility Shannon Valley, Ballynamona, Summerhill, Co. Meath.
Waste Facility Permit MH-19-0003-02

General Construction Waste Carrier Thorntons Waste Collection Permit NWCPO-


09-01190-05
Receiving Facility Thorntons Recycling Centre, Kileen Road, Dublin 10
Waste Licence W0044-02

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Invasive Species
Species listed on the Third Schedule of S.I. 477/2011 (as amended)
Chapter 11, Biodiversity is contained within Volume II of the EIAR. A survey for invasive
species was undertaken by the project ecologists, Scott Cawley. It identified that there
are none present on site. It is not intended to import soils to the site as part of the
proposed development and accordingly there is no risk of importing invasive species.

8.0 WASTE RECORD KEEPING

It is the responsibility of the C&D Waste Officer that a written record of all quantities and
natures of all wastes reused / recycled and exported off-site during the project are
maintained in a Waste File at the Project office.

The following information shall be recorded for each load of waste exported off-site:

➢ Waste Type EWC Code and description.


➢ Volume of waste collected.
➢ Waste collection contractor’s Waste Collection Permit Number and collection receipt
including vehicle registration number.
➢ Destination of waste load including Waste Permit / Licence number of facility.
➢ Description of how waste at facility shall be treated i.e. disposal / recovery / export
➢ Details of all Article 27 declarations

The waste records shall be issued to Fingal County Council as required / requested.

Where practicable, a computerised monitoring tool may be employed. This system will
enable the Contractor to measure and record the quantity of waste generated, and
identify possible savings on wastage. Thus, each consignment of C&D waste taken from
site will be subject to documentation and recording. An indicative template is contained
in Appendix II to ensure that full traceability of materials to its final destination.

Verifiable and validated tracking and authorisation documentation will be maintained for
all wastes destined for re-use, recovery, recycling or disposal. Justification will also be
provided where a disposal option had been employed.

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Kenelm - Construction Waste Management Plan


9.0 CONSTRUCTION WASTE MANAGEMENT AUDITING

The effectiveness of a Waste Management Plan (WMP) and its implementation, will be
subject to regular audits by the C&D Waste Officer throughout the duration of the project
in accordance with the Audit Plan (to be developed during the works).

The regular audits will focus on materials inputs to the project and the waste outputs for
each operation identifying additional opportunities for waste reduction, re-use and
recycling.

The audits will also investigate the operational factors and management policies that
contribute to the generation of waste and identify appropriate corrective actions, where
necessary.

Performance targets will be developed, e.g. an 85% overall recycling target, successes
and failures will be recorded and Action Plans will be developed to address any issue
which arise.

Inspections of the waste storage areas will be undertaken on a weekly basis, issues
relating to housekeeping, inappropriate storage and / or segregation will be actioned at
the earliest practicable opportunity.

The C&D Waste Officer will record the findings of the audits, including waste types
identified, quantities of waste arising, final treatments and cost, in a report to be available
to the Local Authority as required during the course of the works.

Details of the inputs of materials to the construction site and the outputs of wastage
arising from the project will be investigated and recorded in the Final Waste Audit, which
will identify the amount, nature and composition of the waste generated on the site.

The Final Waste Audit will examine the manner in which the waste is produced and will
provide a commentary highlighting how management policies and practices may
inherently contribute to the production of construction and demolition waste.

The measure waste quantities will be used to qualify the costs of management and
disposal in a Waste Audit Report, which will also record lessons learned from these
experiences, which can be applied to future projects.

10.0 WASTE EXPORT PERMITS/LICENCES

It is the responsibility of the C&D Waste Officer that a written record of all quantities and
natures of all wastes reused / recycled and exported off-site during the project are
maintained in a Waste File at the Project office.

The groundworks contractor will be responsible for the excavation of soils and their
subsequent transport off-site to a permitted waste acceptance facility.

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The groundworks contractor’s vehicles exporting material off-site will operate under a
valid Waste Collection Permit.

The groundworks contractor’s vehicles shall transport waste materials from the site to
appropriately permitted / licenced facilities.

Copies of all relevant Waste Collection Permits and Waste Facility Permits / Waste
Licences shall be maintained by the C&D Waste Officer and are detailed below in
Appendix I.

All monthly waste logs shall include the gate receipt from the facility accepting the waste
load. This receipt shall correspond with the load removed from site.

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Appendix I

Decision tree for determining whether a material is a by-product

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APPENDIX II

Exported waste off-site Monthly Log


Waste Receipt
Facility to which waste Facility Waste Permit / Filed Y / N
Date Haulier Waste Collection Permit # Vehicle Reg Waste Description LoW Code Load Size (tonnes) Waste Descriptions LoW Code
sent Licence Number

Soil and Stones 17 05 04 17 05 04 Soils and Stones other than those mentioned in 17 05 03

17 01 07 Mixture of concrete, bricks, tiles and ceramics other than those mentioned in 17 01 06
17 01 01 Concrete
17 01 02 Brick
17 01 03 Tiles and Ceramics
13 02 08* Engine, gear and lubricating oils
16 01 07 Ferrous Metal

20 03 01 Mixed municipal waste (Canteen)


17 02 01 Wood

17 02 02 Glass

17 02 03 Plastic

17 04 07 Mixed Metals
17 08 02 Gypsum based construction materials

NOTE This list is not final and shall be expanded as wastes are generated

Kenelm - Construction Waste Management Plan


APPENDIX III

GII Waste Classification Report and Subsoil Assessment

Kenelm - Construction Waste Management Plan


Ground Investigations Ireland

Howth Road

Glenveagh Properties PLC

Waste Classification Report and Subsoil


Assessment

January 2020
DOCUMENT CONTROL SHEET

Project Title Howth Road

Engineer Barrett Mahoney Consulting Engineers

Client Glenveagh Properties PLC

Project No 9298-12-19

Document Title Subsoils Assessment and Waste Classification Report

Rev. Status Author(s) Reviewed By Approved By Office of Origin Issue Date

A Final P Moloney B Sexton B Sexton Dublin 09 January 2020

Ground Investigations Ireland Ltd. present the results of the fieldworks and laboratory testing in accordance with the specification and
related documents provided by or on behalf of the client. The possibility of variation in the ground and/or groundwater conditions
between or below exploratory locations or due to the investigation techniques employed must be taken into account when this report
and the appendices inform designs or decisions where such variation may be considered relevant. Ground and/or groundwater
conditions may vary due to seasonal, man-made or other activities not apparent during the fieldworks and no responsibility can be
taken for such variation. The data presented and the recommendations included in this report and associated appendices are intended
for the use of the client and the client’s geotechnical representative only and any duty of care to others is excluded unless approved
in writing.
CONTENTS

1.0 Preamble............................................................................................................................................ 5
2.0 Purpose & Scope .............................................................................................................................. 5
3.0 Limitations......................................................................................................................................... 5
4.0 Site Location and Layout ................................................................................................................. 6
5.0 Site History ........................................................................................................................................ 6
6.0 Subsurface Exploration ................................................................................................................... 6
6.1. General .............................................................................................................................................. 6
6.2. Trial Pits............................................................................................................................................. 7
7.0 Ground Conditions ........................................................................................................................... 7
7.1. General .............................................................................................................................................. 7
7.2. Groundwater ..................................................................................................................................... 7
7.3. Laboratory Testing ........................................................................................................................... 8
8.0 Asbestos............................................................................................................................................ 8
9.0 Waste Classification ......................................................................................................................... 8
10.0 HazWasteOnLineTM Results ........................................................................................................... 10
11.0 Landfill Waste Acceptance Criteria .............................................................................................. 11
12.0 Final Waste Categorisation ........................................................................................................... 12
13.0 By-Product Suitability .................................................................................................................... 13
14.0 Conclusions & Recommendations ............................................................................................... 14
14.1. Conclusions .................................................................................................................................... 14
14.1.1. Waste Classification ............................................................................................................... 14
14.1.2. Waste Categories .................................................................................................................... 14
14.1.3. Asbestos .................................................................................................................................. 14
14.1.4. By-Product Suitability ............................................................................................................. 14
14.2. Recommendations ......................................................................................................................... 14
14.2.1. Waste Transfer ........................................................................................................................ 14
14.2.2. Removal of Material as a By-Product .................................................................................... 15
15.0 References ...................................................................................................................................... 16
LIST OF TABLES

Table 1 LoW Codes ................................................................................................................................... 10


Table 2 Waste Category for Disposal/Recovery..................................................................................... 11
Table 3 Individual Sample Waste Category ............................................................................................ 12

APPENDICES

Appendix 1 Figures
Appendix 2 Trial Pit Records
Appendix 3 Laboratory Testing
Appendix 4 HazWasteOnLineTM Report
Appendix 5 WAC Data Summary
Appendix 6 Suitable 4 Use Data
Appendix 7 Potential Material Outlets
GII Waste Classification Report January 2020 Waste Classification Report

1.0 Preamble

Ground Investigations Ireland (GII) was appointed by Barrett Mahony Consulting Engineers (BMCE) on
behalf of Glenveagh Properties PLC (Glenveagh) to carry out a Waste Classification and Subsoil
Assessment for a proposed residential development in Howth, Dublin 13. All site investigation works were
carried out under the supervision of a GII Geo-Environmental Engineer. The site investigation works were
completed in December 2019.

2.0 Purpose & Scope

It is understood that as part of the proposed development there will an excavation to accommodate a
basement structure and as such the material which may be excavated and removed from site needs to be
assessed in terms of waste disposal outlets or re use.

The purpose of the waste classification subsoil assessment exercise was as follows.
 Classification, in terms of waste management and final disposal outlets, of material that may require
disposal following excavation during the construction phase; and

 Assess the materials suitability in terms of subsoil quality and potential environmental impact for
removal from site as a by-product.

The scope of the work undertaken to facilitate the waste classification exercise included the following:

 Excavation of twelve (12 No.) trial pits;


 Collection of subsoil samples for chemical analysis;
 Environmental laboratory testing;
 Waste classification; and
 By-product suitability assessment.

3.0 Limitations

GII has prepared this report for the sole use of Glenveagh. No other warranty, express or implied, is made
as to the professional advice included in this report or other services provided by GII.
The conclusions and recommendations contained in this report are based upon information provided by
others and the assumption that all relevant information has been provided by those bodies from whom it
has been requested. Information obtained from third parties has not been independently verified by GII,
unless otherwise stated in this report.
This report has been prepared in line with best industry standards and within the project’s budgetary and
time constraints. The methodology adopted and the sources of information used by GII in providing its
services are outlined in this report.

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The work described was undertaken in December 2019, this report is based on the conditions encountered
and the information available during that period. The scope of this Report and the services are accordingly
factually limited by these circumstances.
GII disclaim any undertaking or obligation to advise any person of any change in any matter affecting the
Report, which may come or be brought to GII’s attention after the date of the Report.
The conclusions presented in this report represent GII’s best professional judgement based on review of
site conditions observed during any site visit and the relevant information available at the time of writing.
The opinions and conclusions presented are valid only to the extent that the information provided was
accurate and complete.
The investigation was focused on a broad assessment of the subsoil quality across the site. The
assessment did not extend to the identification of asbestos containing materials associated with any on-
site structures, ground gases or groundwater.
The waste classification exercise is reflective of and applicable to the ground conditions on site at the time
of the site investigation and sampling. Alterations to the ground conditions or any further excavations carried
out on site following the investigation are not reflected in this report.

4.0 Site Location and Layout

The site is located on the southern side of Howth Road between Sutton Village and Howth Village (Figure
1 Appendix 1). At the time of the assessment the site was an open grassed field and was not in use. The
lands to the south and east were occupied by a golf course. The site is bounded to the north by the Howth
Road and housing to the west.

5.0 Site History

GII reviewed the aerial photographs and historical maps maintained by the Ordnance Survey of Ireland
(OSI) and the google imagery records (Figure 2 to 4). These included the 6-inch maps that were produced
between 1829 and 1842, the 25-inch maps that were produced between 1888 and 1913 and the 6-inch
Cassini Maps that were produced between the 1830’s and 1930’s. The site is undeveloped on all historical
maps. The site is in its current use on all reviewed historical aerial photographs.

6.0 Subsurface Exploration

6.1. General

During the ground investigation a programme of intrusive investigation specified by the Consulting Engineer
was undertaken to determine the sub surface conditions at the proposed site. Regular sampling and in-
situ testing was undertaken in the exploratory holes to facilitate the geotechnical descriptions and to enable
laboratory testing to be carried out on the soil samples recovered during excavation and drilling.

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The procedures used in this site investigation are in accordance with Eurocode 7 Part 2: Ground
Investigation and testing (ISEN 1997 – 2:2007) and B.S. 5930:2015.

6.2. Trial Pits

The trial pits were excavated using a JCB 3CX excavator at the locations shown in Figure 5. The locations
were checked using a CAT scan to minimise the potential for encountering services during the excavation.
The trial pits were sampled, logged and photographed by a Geotechnical Engineer/Engineering Geologist
prior to backfilling with arisings. Notes were made of any services, inclusions, pit stability, groundwater
encountered and the characteristics of the strata encountered and are presented on the trial pit logs which
are provided in Appendix 2 of this Report.

7.0 Ground Conditions

7.1. General

The ground conditions encountered during the investigation are summarised below with reference to insitu
and laboratory test results. The full details of the strata encountered during the ground investigation are
provided in the exploratory hole logs included in the appendices of this report.

The sequence of strata encountered were consistent across the site and are generally comprised;
 Topsoil
 Cohesive Deposits

TOPSOIL: Topsoil was encountered in all the exploratory holes and was present to a maximum depth of
0.4m BGL.

COHESIVE DEPOSITS: Cohesive deposits were encountered beneath the Topsoil and were described
typically as brown slightly sandy slightly gravelly CLAY with occasional subangular to subrounded cobbles.
The secondary sand and gravel constituents varied across the site and with depth, with granular lenses
occasionally present in the glacial till matrix. These deposits had some, occasional or frequent cobble and
boulder content where noted on the exploratory hole logs.

7.2. Groundwater

Groundwater was encountered in three locations TP-01, 05 and 12 at depths of 2.8m, 3.0m and 3.2m BGL
respectively. The recorded groundwater inflows were minor. It should be noted that these exploratory holes
did not remain open for sufficiently long periods of time to establish the hydrogeological regime and
groundwater levels would be expected to vary with the time of year, rainfall, nearby construction and other
factors.

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7.3. Laboratory Testing

In order to assess materials, which may be excavated from site, in terms of waste classification, a selection
of samples collected were analysed for a suite of parameters which allows for the assessment of the soils
in terms of total pollutant content for classification of materials as hazardous or non-hazardous (RILTA
Suite). The suite also allows for the assessment of the soils in terms of suitability for placement at various
categories of landfill. The parameter list for the RILTA suite includes analysis of the solid samples for
arsenic, barium, cadmium, chromium, copper, cyanide, lead, nickel, mercury, zinc, speciated aliphatic and
aromatic petroleum hydrocarbons, pH, sulphate, sulphide, moisture content, soil organic matter and an
asbestos screen.
The RILTA suite also includes those parameters specified in the EU Council Decision establishing criteria
for the acceptance of waste at Landfills (Council Decision 2003/33/EC), which for the solid samples are pH,
total organic carbon (TOC), speciated aliphatic and aromatic petroleum hydrocarbons, BTEX, phenol,
polychlorinated biphenyls (PCB) and PAH.
In line with the requirement of Council Decision 2003/33/EC a leachate was generated from the solid
samples which was in turn analysed for antimony, arsenic, barium, cadmium, chromium, copper, lead,
mercury, molybdenum, nickel, selenium, zinc, chloride, fluoride, soluble sulphate, sulphide, phenols,
dissolved organic carbon (DOC) and total dissolved solids (TDS). The suite was selected due to no
evidence of specific contaminants of concern highlighted in the site history. The laboratory testing was
competed by Element Materials Technology (EMT) in the UK; EMT is a UKAS accredited laboratory. The
full laboratory report is included in Appendix 3.

8.0 Asbestos

Asbestos fibres were not detected in the samples. The laboratory did not identify asbestos containing
materials (ACMs) in the samples.

9.0 Waste Classification

GII understands that any materials which may be excavated from site would meet the definition of waste
under the Waste Framework Directive. This may not be the case at the time of excavation when all or some
of the materials may have been declared a by-product in line with Article 27 of the European Communities
(Waste Directive) Regulations 20111.

Excess soil and stone resulting from excavation works (the primary purpose of which is not the production
of soil and stone) may be declared a by-product if all four by-product conditions are met.2

1
S.I. No. 126/2011 - European Communities (Waste Directive) Regulations 2011 (Article 27).
2
Irish EPA (June 2019), Guidance on Soil and Stone By-Products.

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a) further use of the soil and stone is certain;

b) the soil and stone can be used directly without any further processing other than normal industrial
practice;

c) the soil and stone is produced as an integral part of a production process; and

d) further use is lawful in that the soil and stone fulfils all relevant requirements for the specific use
and will not lead to overall adverse environmental or human health impacts.

Due to the varying levels of anthropogenic materials encountered in the made ground there are potentially
two sets of List of Waste (LoW)3 codes with “mirror” entries which may be applied to excavated materials
to be removed from site.

1. 17-05-03* (soil and stone containing dangerous substances, classified as hazardous) or 17-05-04
(soil and stone other than those mentioned in 17-05-03, not hazardous); or

2. 17-09-03* (other construction and demolition wastes (including mixed wastes) containing
hazardous substances) or 17-09-04 (mixed construction and demolition wastes other than those
mentioned in 17 09 01, 17 09 02 and 17 09 03).

Where waste is a mirror entry in the LoW, it can be classified via a process of analysis against standard
criteria set out in the Waste Framework Directive. The assessment process is described in detail in
guidance published by the Irish (EPA Waste Classification, List of Waste & Determining if Waste is
Hazardous or Non-Hazardous, June 2015) and UK regulatory authorities (Guidance on the Classification
and Assessment of Waste: Technical Guidance WM3, 2015). The assessment involves comparison of the
concentration of various parameters against defined threshold values.

The specific LoW code which should be applied to the material at each sample location is summarised in
Table 1 below. These codes are only applicable where the material is being removed for site as a waste.

GII use HazWasteOnlineTM, a web-based commercial waste classification software tool which assists in the
classification of potentially hazardous materials. This tool was used to determine whether the materials
sampled are classified as hazardous or non-hazardous. The use of the online tool is accepted by the EPA
(EPA 2014).

The conclusions presented in the report are based on GII’s professional opinion. It should be noted that
the environmental regulator (in this case the EPA) and the waste acceptor (in this case a landfill
operator) shall decide whether a waste is hazardous or non-hazardous and suitable for disposal at
their facility.

3
Formerly European Waste Catalogue Codes (EWC Codes)

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10.0 HazWasteOnLineTM Results

In total, thirty (30 No.) samples were assessed using the HazWasteOnLineTM Tool. All samples were
classified as being non-hazardous. The complete HazWasteOnLineTM report for all samples is included in
Appendix 4.

The specific LoW code which should be applied to the material at each SI location is summarised in Table
1 below. The assigning of the LoW code is based on observations recorded in the trial pits, an estimation
of the % of anthropogenic material present and the results of the HazWasteOnlineTM output. The final LoW
codes applied at the time of disposal may vary due to variations in % of anthropogenic material observed
in the excavation phase. Where there is in excess of 2%4 anthropogenic material observed the LoW code
17 09 04 may be applied.

Table 1 LoW Codes


Hazardous/Non- Asbestos Type
SI Location Depth (m) LoW Code
Hazardous if Present
TP-01 0.00-1.00 Non-Hazardous NAD5 17 05 04
TP-02 0.00-1.00 Non-Hazardous NAD 17 05 04
TP-02 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-02 2.00-3.00 Non-Hazardous NAD 17 05 04
TP-03 0.00-1.00 Non-Hazardous NAD 17 05 04
TP-03 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-04 0.00-1.00 Non-Hazardous NAD 17 05 04
TP-05 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-05 2.00-3.00 Non-Hazardous NAD 17 05 04
TP-05 3.00-3.50 Non-Hazardous NAD 17 05 04
TP-06 0.00-1.00 Non-Hazardous NAD 17 05 04
TP-06 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-06 2.00-3.10 Non-Hazardous NAD 17 05 04
TP-07 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-07 2.00-3.00 Non-Hazardous NAD 17 05 04
TP-07 3.00-3.30 Non-Hazardous NAD 17 05 04
TP-08 0.00-1.00 Non-Hazardous NAD 17 05 04
TP-08 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-09 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-09 2.00-3.00 Non-Hazardous NAD 17 05 04
TP-09 3.00-3.30 Non-Hazardous NAD 17 05 04
TP-10 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-10 2.00-3.00 Non-Hazardous NAD 17 05 04
TP-10 3.00-3.20 Non-Hazardous NAD 17 05 04
TP-11 1.00-2.00 Non-Hazardous NAD 17 05 04

4
EPA (2017) - Draft Guidance Note on Soil Recovery Waste Acceptance Criteria.
5
NAD – no asbestos detected.

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Hazardous/Non- Asbestos Type


SI Location Depth (m) LoW Code
Hazardous if Present
TP-11 2.00-3.00 Non-Hazardous NAD 17 05 04
TP-11 3.00-3.40 Non-Hazardous NAD 17 05 04
TP-12 0.00-1.00 Non-Hazardous NAD 17 05 04
TP-12 1.00-2.00 Non-Hazardous NAD 17 05 04
TP-12 2.00-3.00 Non-Hazardous NAD 17 05 04

11.0 Landfill Waste Acceptance Criteria

Waste Acceptance Criteria (WAC) have been agreed by the EU (Council Decision 2003/33/EC) and are
only applicable to material if it is to be disposed of as a waste at a landfill facility. Each individual member
state and licensed operators of landfills may apply more stringent WAC. WAC limits and the associated
laboratory analysis are not suitable for use in the determination of whether a waste is hazardous or non-
hazardous. The data have been compared to the WAC limits set out in Council Decision 2003/33/EC as
well as the specific WAC which the EPA have applied to the Integrated Materials Solutions (IMS) Landfill
in north County Dublin. The IMS landfill has higher limits for a range of parameters while still operating
under an inert landfill licence. The WAC data considered in combination with the waste classification
outlined in Section 12.0 allows the most suitable waste category to be applied to the material tested. The
applicable waste categories are summarised in Table 2. A summary of the WAC data is presented in
Appendix 5. The waste category assigned to each sample is summarised in Table 3.

Table 2 Waste Category for Disposal/Recovery


Waste Category Classification Criteria
Category A Soil and Stone only which are free from6 anthropogenic materials
Unlined Soil Recovery such as concrete, brock timber. Soil must be free from
Facilities “contamination” e.g. PAHs, Hydrocarbons.
Category B1 Reported concentrations within inert waste limits, which are set out by
Inert Landfill the adopted EU Council Decision 2003/33/EC establishing criteria
and procedures for the acceptance of waste at landfills pursuant to
Article 16 and Annex II of Directive 1999/31/EC (2002).
Results also found to be non-hazardous using the HWOL7
application.
Category B2 Reported concentrations greater than Category B1 criteria but less
Inert Landfill than IMS Hollywood Landfill acceptance criteria, as set out in their
Waste Licence W0129-02.
Results also found to be non-hazardous using the HWOL application.

6
Free from equates to less than 2%.
7
HazWasteOnLineTM Tool.

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Category C Reported concentrations greater than Category B criteria but within


Non-Haz Landfill non-haz landfill waste acceptance limits set out by the adopted EU
Council Decision 2003/33/EC establishing criteria and procedures for
the acceptance of waste at landfills pursuant to Article 16 and Annex
II of Directive 1999/31/EC (2002).
Results also found to be non-hazardous using the HWOL application.
Category C 1 As Category C but containing < 0.001% w/w asbestos fibres.
Non-Haz Landfill
Category C 2 As Category C but containing >0.001% and <0.01% w/w asbestos
Non-Haz Landfill fibres
Category C 3 As Category C but containing >0.01% and <0.1% w/w asbestos
Non-Haz Landfill fibres.
Category D Results found to be hazardous using HWOL Application.
Hazardous Treatment
Category D 1 Results found to be hazardous due to the presence of asbestos
Hazardous Disposal (>0.1%).

12.0 Final Waste Categorisation

All samples were assessed in terms of waste classification using the HazWasteOnLineTM tool and also the
WAC set out in Council Decision 2003/33/EC and the IMS specific WAC to give a final waste categorisation
to determine the most appropriate disposal route for any waste generated. The final and most applicable
waste category for each sample is summarised in Table 3.

Table 3 Individual Sample Waste Category

Sample ID Sample Depth (m) Material Type Waste Category LoW Code
TP-01 0.00-1.00 Clay A 17 05 04
TP-02 0.00-1.00 Clay A 17 05 04
TP-02 1.00-2.00 Clay A 17 05 04
TP-02 2.00-3.00 Clay A 17 05 04
TP-03 0.00-1.00 Clay A 17 05 04
TP-03 1.00-2.00 Clay A 17 05 04
TP-04 0.00-1.00 Clay A 17 05 04
TP-05 1.00-2.00 Clay A 17 05 04
TP-05 2.00-3.00 Clay A 17 05 04
TP-05 3.00-3.50 Clay A 17 05 04
TP-06 0.00-1.00 Clay A 17 05 04
TP-06 1.00-2.00 Clay A 17 05 04
TP-06 2.00-3.10 Clay A 17 05 04
TP-07 1.00-2.00 Clay A 17 05 04
TP-07 2.00-3.00 Clay A 17 05 04

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Sample ID Sample Depth (m) Material Type Waste Category LoW Code
TP-07 3.00-3.30 Clay A 17 05 04
TP-08 0.00-1.00 Clay A 17 05 04
TP-08 1.00-2.00 Clay A 17 05 04
TP-09 1.00-2.00 Clay A 17 05 04
TP-09 2.00-3.00 Clay A 17 05 04
TP-09 3.00-3.30 Clay A 17 05 04
TP-10 1.00-2.00 Clay A 17 05 04
TP-10 2.00-3.00 Clay A 17 05 04
TP-10 3.00-3.20 Clay A 17 05 04
TP-11 1.00-2.00 Clay A 17 05 04
TP-11 2.00-3.00 Clay A 17 05 04
TP-11 3.00-3.40 Clay A 17 05 04
TP-12 0.00-1.00 Clay A 17 05 04
TP-12 1.00-2.00 Clay A 17 05 04
TP-12 2.00-3.00 Clay A 17 05 04

13.0 By-Product Suitability

Based on the analysis of the samples collected from the on-site excavations the material sampled is free
of contamination (PAHs, TPH, asbestos etc.). The material sampled was comprised of natural subsoils
which were free of anthropogenic materials. Following an appraisal of the chemical analysis and the
absence of anthropogenic materials the subsoils sampled are suitable for removal from site as a by-product
which will not lead to overall adverse environmental or human health impacts. If the material is to be
removed as a by-product then the producer of the by-product must demonstrate that all four criteria outlined
in Section 9 have been satisfied.

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14.0 Conclusions & Recommendations

The conclusions and recommendations given and opinions expressed in this report are based on the
findings of the site investigation works and laboratory testing undertaken. Where any opinion is expressed
on the classification of material between site investigations locations, this is for guidance only and no liability
can be accepted for its accuracy. No responsibility can be accepted for conditions which have not been
revealed by the findings at the site investigation locations.

14.1. Conclusions

14.1.1. Waste Classification

Based on the results of the HazWasteOnLineTM tool the material sampled across the site can be classified
as non-hazardous.

14.1.2. Waste Categories

The most applicable waste category for each of the samples has been presented in Table 3, in all cases
the samples have been classified as Category A indicating that the subsoils across the site if excavated
and removed for disposal can be considered to be Category A.

14.1.3. Asbestos

Asbestos was not detected in the soil samples.

14.1.4. By-Product Suitability

The material sampled is suitable for removal from site as a by-product which will not lead to overall adverse
environmental or human health impacts.

14.2. Recommendations

14.2.1. Waste Transfer

In the event that material is excavated for removal from site, any firm engaged to transport waste material
from site and the operator of any waste facility that will accept subsoils excavated from this site should be
furnished with, at a minimum, copies of the full unabridged laboratory reports and HazWasteOnLineTM
report for all samples presented in this report.

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The material on site if excavated and removed as a waste it should be removed to the most appropriate
facility under the waste categories and LoW codes identified in Table 3. Potential outlets for the various
waste categories are presented in Appendix 6, this list is not exhaustive and applicable at the time of the
writing this report.

The material across the site if excavated should be removed from site to an appropriate facility under either
the LoW code 17 05 04 or 17 09 04. Where during excavation there is noted to be in excess of 2%
anthropogenic material the appropriate LoW code which should be applied is 17 09 04. The most
appropriate LoW code based on the site investigation observations and testing is 17 05 04.

14.2.2. Removal of Material as a By-Product

The material sampled is suitable from an environmental impact perspective for removal from site as a by-
product in line with Article 27 of the European Communities (Waste Directive) Regulations 2011. The
material may only be declared a by-product if all four by-product conditions are met.

a) further use of the soil and stone is certain;

b) the soil and stone can be used directly without any further processing other than normal industrial
practice;

c) the soil and stone is produced as an integral part of a production process; and

d) further use is lawful in that the soil and stone fulfils all relevant requirements for the specific use
and will not lead to overall adverse environmental or human health impacts.

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15.0 References
Environment Agency (2013). Waste Sampling and Testing for Disposal to Landfill. Available at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/321207/Sampling_and_test
ing_of_waste_for_landfill.pdf

Environment Agency (2015). Technical Guidance WM3 - Guidance on the classification and assessment
of waste (1st edition 2015) Technical Guidance WM3. Available at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/427077/LIT_10121.pdf

Environmental Protection Agency (EPA) (2014). Letter to Licences Re: Waste Classification & Haz Waste
On-LineTM. Available at:
https://www.hazwasteonline.com/marketing/media/downloads/EPA%20Waste%20classification%20comm
unication%2020may14.pdf

Environmental Protection Agency (EPA) (2015). Waste Classification List of Waste & Determining if
Waste is Hazardous or Non-hazardous. Available at:
https://www.epa.ie/pubs/reports/waste/stats/wasteclassification/EPA_Waste_Classification_2015_Web.pd
f

Environmental Protection Agency (EPA) (2017). Draft Guidance Note on Soil Recovery Waste Acceptance
Criteria. Available at: http://www.epa.ie/pubs/consultation/soilrecoveryconsultation/

Environmental Protection Agency (EPA) (June 2019). Guidance on Soil and Stone By-products in the
context of article 27 of the European Communities (Waste Directive) Regulations 2011 Version 3. Available
at: https://www.epa.ie/pubs/advice/waste/product/Guidance_on_Soil_and_Stone_By_Product.pdf

Association of Geotechnical and Geoenvironmental Specialists (2019). Waste Classification for Soils – A
Practitioners Guide.

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